KYC & AML/CFT Policy

Barter Funds is committed to preventing money laundering (ML), terrorism financing (TF), and proliferation financing (PF) through our platform. This Know Your Customer (KYC) and Anti-Money Laundering / Counter-Terrorism Financing (AML/CFT) Policy sets out how we identify, verify, and monitor our customers and their transactions. This Policy is implemented in accordance with: • The Financial Action Task Force (FATF) 40 Recommendations, including those applicable to Virtual Asset Service Providers (VASPs). • Ghana's Anti-Money Laundering Act, 2008 (Act 749) as amended, and the AML/CFT Regulations. • The Bank of Ghana's guidelines on payment service providers and virtual assets. • The Cybersecurity Act, 2020 (Act 1038) of Ghana. • Nigeria's AML/CFT/CPF Regulations and CBN requirements for supported Nigerian corridors. • Kenya's Proceeds of Crime and Anti-Money Laundering Act for supported Kenyan corridors. • Applicable United Nations Security Council sanctions resolutions and national sanctions lists. Where local law is stricter than this Policy, local law prevails.

"CDD" means Customer Due Diligence. "EDD" means Enhanced Due Diligence. "SDD" means Simplified Due Diligence. "PEP" means a Politically Exposed Person. "Beneficial Owner" means the natural person who ultimately owns or controls a customer or 25% or more of it. "STR/SAR" means a Suspicious Transaction or Suspicious Activity Report. "Sanctions" means targeted financial sanctions imposed by the UN, EU, US OFAC, UK OFSI, or national authorities. "VASP" means a Virtual Asset Service Provider. "Travel Rule" means the FATF requirement to obtain, hold, and transmit originator and beneficiary information for virtual asset transfers.

KYC verification is mandatory before any user can: • Buy, sell, send, or receive digital assets. • Redeem gift cards. • Use Concierge Pay. • Deposit or withdraw funds. • Access or hold a Barter Wallet balance. You may browse the platform and view exchange rates without verification, but no Transaction may be initiated or completed until KYC is approved.

We apply CDD measures when establishing a business relationship, when carrying out occasional transactions above applicable thresholds, when there is suspicion of ML/TF, and when we doubt the accuracy of previously obtained identification data. CDD includes: • Identifying the customer and verifying identity using reliable, independent documents and data. • Identifying and verifying beneficial owners for legal-entity customers. • Obtaining information on the purpose and intended nature of the relationship. • Ongoing monitoring of transactions to ensure they are consistent with our knowledge of the customer.

We apply EDD for higher-risk customers and situations, including: • Politically Exposed Persons (PEPs), their family members, and close associates. • Customers based in or transacting with high-risk jurisdictions identified by FATF. • Complex, unusually large, or unusual patterns of transactions. • Business accounts and high-value corridors. • Customers whose profile or transaction behaviour is inconsistent with expected activity. EDD measures include obtaining senior management approval to establish or continue the relationship, establishing the source of funds and source of wealth, and conducting enhanced ongoing monitoring.

We may apply Simplified Due Diligence only where the ML/TF risk is demonstrably low, the information is publicly available or reliably verified, and applicable law permits. SDD never applies where there is suspicion of ML/TF or where sanctions or PEP status applies.

To complete KYC, you must submit a valid, unexpired, government-issued photo ID from: • Ghana National ID Card (Ghana Card). • International Passport. • Driver's Licence. The document must be clearly legible, showing all text and the photo, with a front and back image where applicable, accompanied by a live selfie. We do not accept photocopied, damaged, expired, or obscured documents, or digital images of screens. For business accounts, we additionally require certificate of incorporation, ownership structure, and beneficial-owner identification.

Verification follows these steps: 1. Submit: complete your personal details and upload your ID and selfie in the app. 2. Review: our compliance team reviews submissions, typically within one (1) to twenty-four (24) hours. 3. Decision: you are notified of approval, or of rejection with a reason so you can resubmit. Transaction limits are tiered according to your verification level and risk profile. Higher tiers or business accounts may require additional documentation and approval. Limits are published on our Fees page and in the app.

For corporate or business users, we identify the natural persons who ultimately own or control the entity (directly or indirectly at 25% or more), the senior managing officials, and the nature of the business. We verify beneficial-ownership information using reliable documents and update it periodically and upon change.

We conduct ongoing monitoring of transactions throughout the relationship to detect unusual or suspicious activity and to keep our knowledge of the customer current. We may require periodic re-verification, additional information, or a fresh identity check where the risk profile changes, where documents expire, or where regulation requires. Failure to comply with re-verification may result in account restriction until verification is completed.

We screen customers, beneficial owners, beneficiaries, and counterparties against applicable sanctions lists (including UN, EU, US OFAC, UK OFSI, and national lists) and PEP databases at onboarding and on an ongoing basis. Where a match or potential match is identified, we take appropriate action, which may include refusing the relationship, freezing funds, and reporting to the relevant authority.

We monitor transactions for patterns and thresholds that may indicate ML/TF/PF, structuring (smurfing), rapid in-and-out movement, or inconsistent behaviour. Thresholds are risk-based and may be adjusted. Transactions meeting defined criteria are escalated for compliance review, which may result in additional information requests, delays, rejection, or a report.

Where we have reasonable grounds to suspect that a Transaction or activity is linked to ML, TF, PF, fraud, or other criminal conduct, we file a Suspicious Transaction Report (STR) or Suspicious Activity Report (SAR) with the relevant Financial Intelligence Centre or authority as required by law, typically without notice to the customer and as soon as practicable. We are prohibited from tipping off any person about a report or investigation.

We apply specific controls to prevent the platform from being used to finance terrorism or the proliferation of weapons of mass destruction. This includes sanctions screening of designated persons and entities, monitoring for indicators of TF/PF, and cooperating with authorities. We do not provide services to any person or entity designated under UN Security Council resolutions or applicable national sanctions.

As a Virtual Asset Service Provider, we comply with the FATF Travel Rule for virtual asset transfers. We obtain, hold, and transmit required originator and beneficiary information for virtual asset transfers between VASPs, and take reasonable steps to identify counterparties and to manage risks where a counterparty VASP cannot be identified or is in a non-compliant jurisdiction. We may refuse, suspend, or reject transfers that do not meet these requirements.

We retain KYC records, transaction records, and supporting documentation for a minimum of five (5) years after the end of the business relationship or the date of the Transaction, and longer where required by law. Records are kept in a manner that allows them to be retrieved promptly for inspection by competent authorities.

Customers must not attempt to structure transactions to evade thresholds, to tip off any person about an investigation or report, or to use the platform to conceal or disguise the origin of funds. Such conduct is a serious breach of these Terms and the law, and will result in account closure, fund freezing, and reporting to authorities.

We do not provide Services to persons located in, or transactions involving, jurisdictions subject to FATF calls for action or comprehensive sanctions. We may restrict or refuse services involving high-risk jurisdictions identified by FATF or national authorities, and may apply EDD or decline transactions at our discretion.

We cooperate fully with the Financial Intelligence Centre, law enforcement, regulators, and other competent authorities, including by responding to information requests, court orders, and production orders, and by implementing freezing and seizure orders as required.

Where a customer fails to comply with KYC/AML requirements, provides false information, is found on a sanctions list, or is linked to suspicious activity, we may refuse or delay a Transaction, restrict or close the account, freeze funds pending investigation, and report to the authorities. No refund obligation arises where funds are lawfully frozen or seized.

KYC and AML data is processed under our Privacy Policy and applicable data protection laws. Because such data is retained under legal obligation, certain erasure rights do not apply to it during the retention period. Access is restricted to authorised compliance personnel and competent authorities.

We maintain a risk-based AML/CFT compliance program with a designated compliance officer, written procedures, risk assessment, ongoing training for staff, and independent oversight. We review and update the program to reflect changes in law, risk, and our business.

For compliance questions, to report suspicious activity, or to raise a concern in confidence, contact our compliance team: Email: compliance@barterfunds.com Support: support@barterfunds.com WhatsApp: +233 53 036 7164 We do not tolerate retaliation against good-faith reporting of compliance concerns.